cssf, European Commission, FATF, supervision

EC Supranational risk assessment 2022

On 27 October, European Comision published revised supranational risk assessment.

First supranational risk assessment (SNRA) was published in 2017 and the second in 2019. The 2022 Commission SNRA is made up of two documents: this report and a detailed Staff Working Document, which read together provide a comprehensive mapping of risks on all relevant areas, as well as the necessary recommendations to counter them.

Let’s name main crucial topics which need our immediate attention and action based on the generic overview set out in the Report on SNRA:

  1. Within the financial sector, lack of clear and consistent rules, inconsistent AML/CFT supervision across the internal market, and insufficient coordination and exchange of information among FIUs, continue affecting the EU’s ability to correctly address ML/TF risks
  2. AML/CFT competent authorities in the Member States often appear to find it difficult to supervise the sector in line with a risk-based approach
  3. EU ‘single rulebook’ on AML/CFT
  4. Increased on-site and thematic inspections by supervisors as a mitigation factor for proper AML/CFT supervision
  5. Provision of training and guidance on risk factors such as non-face-to-face business relationships or transactions, offshore professional intermediaries and customers, and complex or shell structures.
  6. Member States should ensure that service providers offering advice to undertakings on capital structure, industrial strategy and related matters, and advice and services relating to mergers and the purchase of undertakings, comply with their beneficial owner obligations.
  7. Investor citizenship and investor residence schemes – Member States should abolish investor citizenship schemes and thoroughly assess ML/TF risks in their investor residence schemes.

The Annex I and II outline main methodology and risks criteria for appropriate AML/CFT risk assessment which has to be implemented for each supervised entity as well as regulated and non-regulated investment funds.

It all starts with a conversation, let’s start our and bring the change.

FUND AML will help you to implement a proper Risk Assessment

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